CODE OF ETHICS

Approved by Board of Directors on 26/01/2016

1 Roberto Cavalli S.p.A: Code of Ethics

1.1 Mission and Values
1.2 Validity and Application of the Code
1.3 Diffusion of the Code

2 Ethical Principles

2.1 Compliance with the Law and the Code
2.2 Value of the Person and of Human Resources
2.3 Quality and Professionalism
2.4 Honesty, Fairness, Transparency and Loyalty
2.5 Confidentiality
2.6 Eco - Sustainability

3 Conduct Principles

3.1 Work Safety and Environment Protection Policies
3.2 Conflict of Interests
3.3 Presents, Complimentary Gifts and Other Benefits
3.4 Use of Company Goods and Documents
3.5 Events and Travels
3.6 Prevention and Money Laundering
3.7 Relations with Clients and Protection of Economic Competition

5.1 Relations with Clients
5.2 Relations with Suppliers and Consultants
5.3 Relations with the Organismo di Vigilanza and Control Authorities
5.4 Relations with the Public Administration
5.5 Relations with Political Parties, Unions and Associations or Onluses
5.6 Relations with financial Institutions
5.7 Relations with Media
5.8 Protection of Personal Information

6 Implementation Rules

6.1 Disciplinary System
6.2 Functions of Reference for the Application of the Code
6.3 Coordination with Other Company Procedures

7 Entry into Force and Modifications

1 ROBERTO CAVALLI S.P.A.: CODE OF ETHICS

Roberto Cavalli S.p.A. (hereinafter referred to as the Company) is a company developing its activity within the Haute Couture world market.
The Company adopted this Code of Ethics (hereinafter referred to as the Code) to define ethical and conduct principles to be shared and respected by any person operating on behalf of Roberto Cavalli S.p.A. and the companies in Italy or abroad it directly or indirectly controls (hereinafter referred to as the Group).
This Code of Ethics integrates and is strictly connected with the principles of conduct and provisions established in the Organizational, Management and Control Model adopted by the Company, as to Italian Legislative Decree 231/01 ruling the discipline of the administrative responsibility of juridical persons, companies and associations.

1.1 MISSION AND VALUES

Roberto Cavalli S.p.A. Mission consists in creating products unique in their kind, carefully focusing on the client’s desires and needs while keeping constantly high professional standards.

In the pursuit of its targets, the Company aligned to the following ethical principles:

i) Compliance with the legal provisions and regulations in force in any country in which Roberto Cavalli S.p.A. operates;
ii) Value of the single person and of human resources;
iii) Quality and professionalism;
iv) Honesty, fairness, transparency and loyalty;
v) Confidentiality;
vi) Protection of economic competition;
vii) Transparency;
viii) Eco-sustainability.

Anybody working at any title for the Company and within his/her responsibilities shall commit to observe and ensure the respect of the above-mentioned principles in the name of loyalty, good faith and fairness.

1.2 VALIDITY AND APPLICATION OF THE CODE

This Code of Ethics contains the principles of conduct as well as the provisions addressed to: Directors and members of the Corporate Body, employees, collaborators and anybody operating in the name and on behalf of Roberto Cavalli S.p.A. or companies of the Group (hereinafter referred to as Recipients).
Besides this, the Group requests the adoption of a conduct coherent with the principles and provisions ratified in this Code by any Supplier and Partner.
This Code of Ethics shall be valid in any European country were the Group operates, even in consideration of cultural, social and economic differences of each single reality.
Recipients shall know and respect the Code contents in view of an effective collaboration.

1.3 DIFFUSION OF THE CODE

The Company commits itself to ensure the diffusion of this Code and its real and effective application. Besides, the Company commits itself to verify any report of breach to the Code, applying the appropriate sanctions should these be required and avoiding the person who reported the breach suffers any kind of retaliation.

2 ETHICAL PRINCIPLES

2.1 COMPLIANCE WITH THE LAW AND THE CODE

Compliance with legal provisions and regulations existing in the countries where the Group operates is one of the essential principles which the activities developed in the name and on behalf of Roberto Cavalli S.p.A. must inspire to.

The Company considers as essential even the compliance with the conduct principles and provisions contained in this Code, according to which any Recipient shall:

- provide his/her highest collaboration to ensure the comprehension and the respect of the Code, standards, procedures and safety regulations;

- promptly inform the Organismo di Vigilanza about any breach, even if just alleged, to this Code they may have directly or indirectly detected;

- avoid any conduct in contrast with the provisions of the Code;

- report to their direct superior or the Organismo di Vigilanza about any direct or indirect information which may be considered as a breach to the Code, as well as any request of breach they may be directly addressed about.

2.2 VALUE OF THE PERSON AND OF HUMAN RESOURCES

In consideration of the central importance of human resources, the Company aims to keep and encourage a positive working environment, oriented towards the protection of individual freedom, dignity and inviolability as well as to the principles of integrity in interpersonal relationships.
Personnel selection and hiring shall be performed within the most rigorous respect of the procedures and inspired to transparency principles in the assessment of the requirements of competency and professionalism, individual skills and potentiality. The Company opposes any behavior or attitude that is discriminatory or damaging to the individual, his/her preferences and beliefs.
Any form of psychological, physical and sexual harassment is forbidden as well as any form of labor exploitation.
The Company trusts any employee to do his/her better in creating a serene and respectful work environment. Therefore, it will not allow and accept conducts such as being at work under the effect of alcohol, drug or similar things or exchange or use such substances while working.

2.3 QUALITY AND PROFESSIONALISM

The Company is constantly engaged to ensure the quality of his products. In the pursuit of such goal, the Company considers as a prerequisite that its resources and third parties with which he operates develop their activity with reliability and professionalism.
Since ever, the quality of Roberto Cavalli products is supervised, optimized and constantly innovated even through a quality management system which offers uniformity, transparency and general improvement of processes and products.
Each Recipient shall carry out his/her work activity and develop his/her performances with care, efficiency and fairness, with the best use of tools and time and in compliance with the responsibilities related to the requested tasks.

2.4 HONESTY, FAIRNESS, TRANSPARENCY AND LOYALTY

Honesty

Honesty is the main principle to any Company activity and represents the essential value of the Company organization management.
In no case, the pursuit of the Company interests can justify a dishonest conduct

Fairness and Transparency

The Company engages itself to operate in a clear and transparent way without favoring any group of interest or single person.
Recipients shall not use for personal purposes information, goods and tools they are provided with for the development of their function or task, and they shall not accept or make, for themselves or towards others, pressures, recommendations or reports which may cause damage to the company or illicit advantages for themselves, the company or third parties.
Recipients shall refuse and shall not promise illicit money or other benefits.

Loyalty

The Company believes that loyalty towards both the Company and other persons is an essential principle to create a serene and proactive working environment.

2.5 CONFIDENTIALITY

Recipients shall ensure the highest confidentiality to news, data and information about the Company’s assets or business, in compliance with the existing law requirements, regulations and procedures. Recipients shall not use such confidential information for purposes which are not related to the exercise of their function or task.
The Company protects the personal data processed in the framework of its activity so as to avoid improper or even illegal use of the same adopting specific procedures aimed at the adequate information for the data subjects.

2.6 ECO - SUSTAINABILITY

The Company pursues the creation of a company system and production process compliant with the law provisions on eco-sustainability with the engagement of fashion producers, suppliers and operators who have based their activity on the respect of environment and people.

3 CONDUCT PRINCIPLES

3.1 WORK SAFETY AND ENVIRONMENT PROTECTION POLICIES

The Company believes that human resources protection and safety is a fundamental element and therefore it diffuses and consolidates the safety culture, developing awareness of risks and promoting responsible conducts in anybody operating on behalf of the Company.
Operations shall be carried out in compliance with safety, prevention and protection measures against work accidents and occupational diseases.

For any activity and decision, the Company shall keep into its consideration:

- The risk assessment, included those which cannot be eliminated,

- The prevention plan, adopting a model able to respond to the best practices about work organization, conditions and environment,

- The aim, where possible, to avoid or eliminate risks at source or to replace the hazardous sources with others with lesser risks,

- The adoption of the necessary collective and individual safety measures,

- The appropriate and complete training to employees.

Within the environment protection perspective common to everybody, the Group engaged itself in the compliance with the law in force in any country it operates.

3.2 CONFLICT OF INTERESTS

The interested parties shall not be in situations or activities which may lead to conflicts of interest with the interests of the Company, or which could interfere with their capability to take impartial decisions.
Some activities showing a conflict of interests are, for instance:

- personal interests (direct or indirect, clear or hidden) of the Recipient in activities with suppliers, clients, competitors or external subjects already in contact with the Company or who want to conduct business with it,

- use of information acquired during the development of the work activity for personal or third party advantage, in contrast with those of the Company,

- manipulation of the function for activities or interests in contrast with those of the Company.

Should the Recipient be in a situation of even potential conflict about the interests of the Company, he shall inform his direct superior or, in the most serious cases, the Organismo di Vigilanza. Besides, the Recipient shall avoid getting in contact with any activity causing the conflict.
The Recipient shall immediately provide his direct superior or, in the most serious cases, the Organismo di Vigilanza with the information which can bring to the assumption or the forecast of a situation of possible conflict with the interests of the Company.
Recipients shall behave in compliance with ethical and lawful standards and specifically in a manner which avoids discrimination, collusion or corruption or bring advantage personally to them or to others.
Recipients, Company Functions or the members of the Board of Directors shall exempt themselves from activities or situations in contrast with the guideline of Italian Legislative Decree 231/2001 and its following modifications and integrations.

3.3 PRESENTS, COMPLIMENTARY GIFTS AND OTHER BENEFITS

In the relationships with clients, suppliers or third parties, no direct or indirect gift or benefit is allowed in the aim to obtain undue advantages of any nature in favor of the activity related to the Company.
However, expressions of commercial courtesy are allowed if of limited economic value and if in compliance with the Company rules or the law which may be applied. These expressions shall neither compromise the reputation and the integrity of the Recipient nor influence his judgment.
In particular, it is forbidden any form of gift to Italian or external public officers or to their relatives, since they could influence the independence of their judgment in the aim to get more favorable treatments or illicit performances or any kind of advantage.

3.4 USE OF COMPANY GOODS AND DOCUMENTS

Each Employee is responsible for the correct use of the goods made available by the Company, be they material or not and including confidential information within their last category.

Each Employee:

- Shall use such goods with the highest care possible avoiding conducts in contrast with the Company procedures established to the use of these same goods.

- Shall avoid the use of such goods in contrast with the existing laws of the Countries where these same goods are used and in general unsuitable uses or uses in contrast with the public morals and policies.

- The use of these goods is strictly forbidden for offences and acts aiming to commit or inspire crimes, including those acts which may express racial intolerance, violence or violation of human rights.

The use of the Company goods for reasons which are not included in the company policies may cause important and serious damages to the same Company.
A non-authorized or improper use which causes damage to the Company shall be pursued with the compensation of the damage and appropriate disciplinary sanctions to the responsible person.

Digital Information

To grant safety, integrity and efficiency of the Company data forwarded or saved in digital format, each Recipient shall:

- Not send e-mail messages containing threats or insults and avoid obscene and offensive terminology. The Recipient shall prevent from expressing inappropriate comments or judgments which may offend a person or the image of the Company, violating therefore its values: for this reason, sexual harassment, racial discriminations and other forms of discrimination shall be sanctioned,

- Avoid any action which may bring an unjustified increase in the data traffic or in the information within the Company network, so not to jam the efficiency of such network which could negatively impact on productivity,
- Not consult internet sites containing offensive, pornographic or other materials against the common morals or laws in force,

- Carefully respect the Company procedures about data safety so not to compromise the protection of the information system,

- Not use unauthorized programs unreliable to the information safety, avoiding the use of unauthorized copied programs for personal, company or third party use.

Confidential Information

Confidential information (projects, offers, strategies, agreements, non-marketed products, client lists, etc.) can externally be divulged only in compliance with the Company procedures.
Confidential information collected by the Recipient cannot be used for personal benefit or for the benefit of his partners, family members or close relatives.

Company Documentation

Each Employee shall keep, according to the Company procedures, the documentation necessary to the development of his task. It shall be possible to verify it whenever requested for controls and examinations.
Such documentation shall clearly show the real nature of each performed operation. Hence, any document kept in a form different from the above-mentioned principles shall not be accepted by the Company.

3.5 EVENTS AND TRAVELS

The organization of events and travels shall be performed in full respect of procedures and instructions the Company may accordingly decide and Employees and Recipients shall respect what decided by the Company about events or travels necessary to their work activity. Of course, events and travels shall be compliant with the needs of their tasks.
Employees and recipients shall observe procedures about advances and travel reimbursements in full respect of transparency, traceability and competence criteria.
The Company shall only reimburse reasonable and authorized expenses in compliance with the related Company procedures.

3.6 PREVENTION AND MONEY LAUNDERING

NIn consideration of the different relationships established by the Company, the Recipient shall adopt a conduct and develop the business in such a way to avoid his/her implication in situations attributable and connected to money laundering from illicit or criminal activities or goods or other utilities of unlawful origin.
Recipients interested by these processes shall comply with the money laundering regulations about the identification of involved objects and dubious operations.
Recipients shall be compliant with both national and international standards and provisions about money laundering prevention.

3.7 RELATIONS WITH CLIENTS AND PROTECTION OF ECONOMIC COMPETITION

The Company shall facilitate the client highest satisfaction providing exhaustive and exact information on the offered products and services so to foster informed choices.
The Company operates in full respect of the rules on protection of economic competition and abstains from implementing and/or promoting conducts which could include forms of unfair competition.

4 TRANSPARENCY IN ACCOUNTING INFORMATION AND INTERNAL CONTROLS

4.1 PRINCIPLE OF TRANSPARENCY

Thanks to correct and precise records, the verification of any operation is made possible by the Company.
Any operation and/or activity shall be lawful, authorized, coherent, documented and verifiable in compliance with the Company procedures.
The Company procedures shall allow any control on operations, authorization processes and execution of the same operations.
Employees and Collaborators performing operations money, goods or other Company utilities shall provide evidence necessary to carry out the control on such operations.

4.2 TRANSPARENCY OF ACCOUNTS

The Company accounts responds to the general principles of truth, accuracy, completeness and transparency of the registered data.
The Recipients of this Code of Ethics shall abstain from committed or omitted conduct which directly or indirectly breaches the regulatory principles and/or the internal procedures about the composition of accounting documents, their presentation outside the Company premises and their keeping.

The Recipients of this Code of Ethics shall also keep and make available, for any performed operation or transaction, the appropriate support documentation for:

➢ Proper book-keeping records
➢ Immediate identification of features and motivations
➢ Easy formal and chronological reconstruction
➢ Verification of the decisional process, authorization and realization, in terms of validity, consistency and fairness as well as the identification of the different levels of responsibility.

The Recipients of this Code of Ethics who should become aware of omissions, forging or negligence in the accounting records or in the support documentation shall immediately inform their direct superior and the Organismo di Vigilanza and/or the General Management.
The Company promotes training and updates for its administrative functions in compliance with the rules (laws or regulations, internal prescriptions, union provisions) about training and accounting document management.

4.3 CONTROLS AND VERIFICATIONS

The Company ensures the access to any information and document to the persons entitled and provides any information fostering controls through its Directors and functions.
During controls and verifications, Directors, Employees and Collaborators shall adopt a transparent and traceable conduct without impeding the activities of control and verification.

5 EXTERNAL RELATIONS

5.1 RELATIONS WITH CLIENTS

The Company shall facilitate the client highest satisfaction providing exhaustive and exact information on the offered products and services so to foster informed choices.
The company operates in full respect of the rules on protection of economic competition and abstains from implementing and/or promoting conducts which could include forms of unfair competition.

5.2 RELATIONS WITH SUPPLIERS AND CONSULTANTS

Purchasing processes shall be based on the research of the maximum possible benefit for the Company to develop its competitiveness on the market besides being linked to concepts and rules of loyalty and impartiality towards any Supplier with the requested requirements. The suppliers’ cooperation for the constant satisfaction of the client through the compliance with the terms of delivery and quality shall be one of the most important guidelines.
SContract agreements with the Suppliers shall be clear and shall prevent, when possible, from entering into contractual relationships which may determine forms of dependency.
In the selection of the Suppliers, it will be important, especially in those countries defined “at risk” by the recognized organizations, to keep into account the offered guaranties about the fundamental rights of workers, of non-discrimination and protection of child labor.Consultants

Consultants are selected according to their competence and reputation, besides their reliability and adoption of values similar to those described in this document. Relationships with consultants are based upon transparent agreements and a constructive dialogue aiming to reach the common purposes in compliance with the standards and principles of this Code of Ethics.

5.3 RELATIONS WITH THE CONTROL BODIES AND CONTROL AUTHORITIES

The Company carefully observes the rules fixed by Control Bodies and Control Authorities for the compliance with the existing standards.
The relations with these Bodies feature a very high cooperation towards the respect of their institutional role and with the engagement to provide a prompt execution of their prescriptions.

5.4 RELATIONS WITH THE PUBLIC ADMINISTRATION

The Company inspires and aligns its conduct to the principles of transparency, fairness and honesty in its relations with the Public Administration avoiding conducts which may generate the impression the Company aims to influence decisions in an inappropriate way or to request treatment of favor.
Relations with Public Officers shall be kept by the appointed functions under regular authorization, in compliance with the highest observance of legal provisions and regulations and they cannot compromise the integrity and reputation of the Company.
In this aim, Recipients shall engage in not offering or promising, directly or through mediators, sums of money or other kinds of economic benefits to public officers or to public service appointed persons so to condition the execution of their duties.
These requirements cannot be circumvented using different forms of contributions which, under the guise of professional appointments, expert advice, advertisement or other, have the same above-mentioned forbidden purposes.

5.5 RELATIONS WITH POLITICAL PARTIES, ASSOCIATIONS AND ONLUSES

The Company does not directly or indirectly finance political parties or single politicians.
Recipients acknowledge and accept that should they be interested in any form of political involvement, they will do it only on personal basis, at their own expenses, outside the working time and not in the Company premises.
Projects designed for public interest or aligned with the interests of the Company shall be cooperated with such institutions if the destination of the economic resources is clear, documented and authorized by the appointed Company Function.

5.6 RELATIONS WITH FINANCIAL INSTITUTIONS

The Company has founded its relations with financial institutions based on fairness and transparency. In the selection of financial institutions, the Company keeps into high consideration their adoption of values similar to those expressed in this Code of Ethics.

5.7 RELATIONS WITH MEDIA

The Company enhances its image even through communication and advertisement.
Relations with the Media are kept by the expressly appointed Company Function in compliance with the principles of fairness, transparency and truth.
It is absolutely forbidden to spread false news.

5.8 PROTECTION OF PERSONAL INFORMATION

The Company grants the protection of personal information¹ and engages itself to process it in compliance with the existing rules of the Countries where it operates. Should the law request it, the Company shall ask the explicit consent to process personal information.
The Company in any case engages itself in processing the collected data with transparency, lawfulness and pertinently to the declared purposes. The Company shall guarantee the security of the stored data.

________________________________________

¹“Personal Information” refers to any information about an identified or identifiable, even indirectly, physical person or a body.

6 IMPLEMENTING RULES

6.1 DISCIPLINARY SYSTEM

The compliance with the Code of Ethics is essential to the Company which therefore applies, in case of breach, through the appropriate functions, the disciplinary system according to the applicable provisions and to the modes and measures proportioned to the breach.

6.1.1. Employees and Directors

As to art. 2104 of the Italian Civil Code, the respect of this Code is a duty to Employees
The disrespect of the Code provisions shall be considered as a serious default to the employment relationship and a disciplinary offence pursuant art. 7 Law 300/1970 and shall imply the payment of damages caused to the Company.
The breach of principles and conducts described in the Code of Ethics will be appropriately prosecuted independently from the potential criminal relevance of conducts and from the instauration of a criminal prosecution for those cases in which conducts are considered as an offence.
For Employees, it will be possible to adopt disciplinary measures compliant with the provisions and logics of the applied employment relationship. Disciplinary measures are warnings or admonition to suspension from work without retribution and in the most serious cases warnings to dismissal. Before applying a disciplinary sanction, the interested person is given the possibility to provide explanations about his/her conduct.

6.1.2. Collaborators, Consultants and Other Third Parties

Collaborators, consultants and independent workers who operate for the Company and its third parties, who have signed this Code of Ethics or an extract of it or anyways the acceptance of its provisions and principles, shall be under the condition to conclude contracts of any nature with the Company and the other subjects in respect of the signed or in any case approved provisions, even for facts concluding from the same, since they are considered as integrant part of the above mentioned contracts. In the light of this, any possible breach of the Code of Ethics, according to its gravity, can legitimate the Company to terminate the existing contract agreements, since such breach can be considered as the cause for an automatic resolution of the contract as to art. 1456 of the Italian Civil Code.
Specific modes to the resolution of the contract agreement will be activated for consultants, collaborators, clients, suppliers and any other subject under a contract agreement with the Company.
Without prejudice, besides, to the potential payment of damages that the Company may have suffered for the breach of the Code of Ethics provisions from the above-mentioned subjects.
Without prejudice, besides, to the potential payment of damages that the Company may have suffered for the breach of the Code of Ethics provisions from the above-mentioned subjects.

6.2 FUNCTIONS OF REFERENCE FOR THE APPLICATION OF THE CODE

The Functions of reference for the application of the Code of Ethics are the following:

- Organismo di Vigilanza: in compliance with Italian Legislative Decree 231/2001, the Body shall assess the possible reported breaches to the Code, performing any verification they consider as necessary and using in this aim any structure of the Group. The Organismo di Vigilanza, once assessed the kind and gravity of the non-compliance, informs the Directors

- Human Resources Director: he/she shall disclose and promote the Code within the Companies of the Group. Together with the Directors and the Organismo di Vigilanza, he/she shall apply the appropriate disciplinary measures in case of breach to the provisions of this Code.

6.3 COORDINATION WITH OTHER COMPANY PROCEDURES

Should even a single provision of this Code of Ethics be in conflict with the provisions established in the Company regulations and procedures, the Code of Ethics will prevail on any of such provisions. However, this Code doesn’t replace the present and future Company procedures, which remain effective as far as they do not contrast the Code.

7 ENTRY INTO FORCE AND MODIFICATIONS

This Code of Ethics has been approved by the Board of Directors of Roberto Cavalli S.p.A. on 26th January 2016 and its entry into force corresponds to its date of approval.

Any variation and/or integration to this Code of Ethics shall be approved by the Board of Directors after consultation with the Organismo di Vigilanza according to what follows:

a. The Organismo di Vigilanza shall periodically examine the Code of Ethics for the produced lawful or company modifications and suggests modifications and/or integrations

If you wish to complete the registration process and/or use the website services offered to those accessing the reserved areas (e.g make a purchase and instrumental activities to the same, including operations relating to administrative and tax obligations, sending of newsletters (where requested), please complete the fields below and accept this Information Note. Conferral of data pursuant to the registration form and/or the purchase of products is not compulsory. However, we must inform you that the aforementioned conferral is required to process your order and complete the contract formalities. Your refusal may make it impossible for us to complete the product purchase procedure and/or provide the requested services. All collected personal data shall be processed mainly using electronic systems and, only very occasionally, paper based systems.

Triboo Digitale S.r.l. with registered office in Viale Sarca, 336 - 20126, Milan (MI) Italy, tax code, VAT number and Milan Business Register no. 02912880966, Share capital € 42,678.00, which is only responsible for managing the sales and transactions on then website, for instance, management of product orders, sales and deliveries, return and warranty management and all other activities related to the sales of products via the website.

To conduct such activities functional to the sale of products via the website, Triboo Digitale processes, in its capacity as co-Data Controller, and in accordance with the applicable privacy code, user data such as name and surname, residence and information on credit cards used by users (such as first and last name of the card holder, card number, expiration date, security code.

Please also be informed that Legislative Decree 196/2003 has a particular regime for the processing of sensitive data, i.e. all personal data that reveals the racial and ethnical origin, religious, philosophical or other beliefs, political opinions, memberships with political parties, trade unions, religious, philosophical or trade union associations or organizations, health conditions and sexual orientation; This data may only be processed after receiving the written consent of the Data Subject. In this regard, some purchases made in the Wellness & Health section may reveal information on the health conditions of the purchaser. In light of the above, if you make any purchases of such products, you may be requested to grant specific consent to allow us to process the data and complete the contract formalities.

Roberto Cavalli may also use your personal data to send emails advertising its products and services, similar to those purchases, unless you refuse this option by exercising your right of opposition as per the procedures below (art. 130 paragraph 4 Legislative Decree 196/2003.

Moreover, where express consent is granted, your personal data may also be processed for marketing purposes such as the mailing of promotional material on products and services different to those already purchased, news, promotions, and also third-party communications from our commercial partners.

Transfer of your personal data outside the European Union is not contemplated. Should the same become necessary, the Data Controller shall be accountable for requesting your specific consent.

This does not include the data relating to your Credit card, which is excluded for any purposes other than checking the existence of such payment means, the payment received and the management of payments further to claim management and contentious procedures. To this purpose, the data will also be processed by the Bank that provides the online payment service, further to the entity that issued the credit card you use to confirm your order.

At present, one of the Chief Data Processors designated to the processing of your personal data is Arcese Logistic S.r.l., who will process the data required to ship the merchandise and manage any returns you may make.Please contact the Customer Care service for a complete list of those designated to processing your Personal Data or send an e-mail to the following address privacy@triboo.it for Roberto Cavalli and privacy@triboo.it for Triboo Digitale.

The categories of those designated to processing the data for the aforementioned purposes, include staff assigned to website management, administration, customer care services, marketing activities (where consent is granted), IT systems and third parties who process data on our behalf (such as, for instance, IT service maintenance, couriers and carriers, legal advisers, enterprises assigned to the realisation and/or management of promotional campaigns, etc.); they can also be disclosed to the public entities authorised to receive the same.

Pursuant to art. 7 of L.Decree. 196/2003, you are entitled to obtain the updating, rectification or integration, erasure and anonymisation of the data. You can also oppose the processing of your personal data for marketing purposes or for sending commercial communications, by contacting Roberto Cavalli at the above indicated mailing addresses or by sending an email to privacy@triboo.it. The same procedures can be used to request the complete updated list of the Chief Data Processors.

INFORMATION NOTICE FOR THOSE INTERESTED IN THE COUTURE SERVICE

AND REQUEST INFORMATION USING THE CONTACT FORM

PERSONAL DATA PROTECTION CODE

UNDER ART. 13 OF LEGISLATIVE DECREE NO. 196 OF 30.06.2003

In accordance with the requirements and provisions of art. 13 of Legislative Decree no. 196 of 30 June 2003, the company
Roberto Cavalli S.p.A., with registered office in (20122) Milan, in Piazza San Babila no. 3, in its capacity of Data Controller, hereby informs all Data Subjects on the scope and purposes of the processing of the collected personal data, the relative communication and dissemination, and the nature of their conferral.

PURPOSE OF THE PROCESSING

The personal, identifying data (name, surname, email and any other personal information provided by the Data Subject on the form) and electronic data collected from the DS and provided spontaneously by the same via the section of the corporate website called "contact us if you are interested in the COUTURE SERVICE", subject of the processing, are used by the Data Controller to correctly process the request forwarded by the DS and reply to the same.

If the DS grants specific consent, the above-mentioned data may be processed for marketing activities and commercial communications of the Data Controller, also by telephone, sms, mms, printed and electronic mail.

PROCESSING OPERATIONS

Personal data is processed using electronic and telematic systems by specifically designated internal employees. In particular, the interested parties will be contacted by the Data Controller's VIP and Couture service managers. Data is stored in electronic archives whose security levels comply with the minimum measures endorsed by the legislature in force.

COMMUNICATION AND DISSEMINATION

The collected data will not be disseminated, sold or exchanged with third-parties without the express consent of the Data Subject, except for any communications to authorised third parties - committed to such confidentiality or appointed as Chief Data Processors under art. 29 of Legislative Decree no. 196/2003 - (e.g. IT support firms) and only where necessary to fulfil the purpose indicated in this Information Notice. Personal data may be communicated to competent authorities as required by the laws in force.

With the optional consent of the Data Subject, personal data may also be communicated to the companies in the Group that the Data Controller belongs to, both in Italy and abroad, for promotional and advertising purposes of the same.

RETENTION TIMES

Personal data is retained for the time required to interact with the Data Subject and exchange information.

As regards the processing for purposes related to the sending of commercial and promotional communications on the Data Controller's services and the sending of information messages regarding its business activities, the data will be retained as foreseen by the laws in force, and further endorsed by the Guarantor for the protection of personal data on 3 March, and unless the Data Subject opposes the processing of the same. The Data Subject can oppose the processing for one or both of the above communication activities independently.

RIGHTS OF THE DATA SUBJECT

You are entitled to execute your rights as illustrated in Arts. 7, 8, 9 and 10 of Legislative Decree no. 196 of June 30, 2003 by contacting the Data Processer. In particular, according to art. 7 you are entitled to obtain confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form. The Data Subject has the right to obtain indications on: a) to receive information on the origin of the personal data; b) on the purpose and processing methods; c) on the logic used in the case where the data is processed using electronic equipment; d) on the personal data of the Controller, the persons in charge and the designated representatives pursuant to Art, 5 paragraph 2; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as Designated Representatives for the Country or Persons in Charge of Processing. The Data Subject has the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. The Data Subject is entitled to oppose, totally or partially: a) processing of personal data, for legitimate reasons, despite them being relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

DATA CONTROLLER, CHIEF DATA PROCESSOR AND PRIVACY COMMUNICATIONS

privacy@robertocavalli.com.

CONFERRAL OF DATA

The conferral of data is optional; however lack of consent to provide the same information will make it impossible for the Data Controller to process the requests submitted.

Conferral of personal data for marketing purposes and communications to third-parties for the above indicated marketing purposes, is optional and will not compromise the processing of the main request.

CONSENT

Pursuant to art. 23 of Legislative Decree no. 196/2003 and the correct processing of the request submitted via the "Contact Us" section of the corporate website, consent to the processing of the above data is necessary as the same are collected outside of any previous contractual agreements

Pursuant to art. 23 of Legislative Decree no. 196/2003, the consent to the processing of personal data is necessary for the marketing purposes illustrated in the "Purpose of the Processing" section. Please note, in accordance with Provision no. 330 of 4 July 2013 issued by the Guarantor for the Protection of Personal Data, that the consent granted for automated procedures also extends to traditional procedures. Without prejudice to the rights already illustrated in the Rights of the Data Subject" paragraph in this Information Notice.

Pursuant to art. 23 of Legislative Decree no. 196/2003 consent is required for the communication of the data to third parties for marketing purposes pursuant to the latter.

INFORMATION NOTICE FOR THOSE REQUESTING INFORMATION USING THE CONTACT FORM

Personal Data Protection Code

UNDER ART. 13 of Legislative Decree no. 196 of 30.06.2003

In accordance with the requirements and provisions of art. 13 of Legislative Decree no. 196 of 30 June 2003, the company Roberto Cavalli S.p.A., with registered office in (20122) Milan, in Piazza San Babila no. 3, in its capacity of Data Controller, hereby informs all Data Subjects on the scope and purposes of the processing of the collected personal data, the relative communication and dissemination, and the nature of their conferral.

PURPOSE OF THE PROCESSING

The personal, identifying data (name, surname, email and telephone number etc.) and electronic data collected from the Data Subjects and provided spontaneously by the same via the section of the corporate website called "contact us”, subject of the processing, are used by the Data Controller to correctly process the request forwarded by the DS and, where necessary, reply to the same.

PROCESSING OPERATIONS

Personal data is processed using electronic and telematic systems by specifically designated internal employees. Data is stored in electronic archives whose security levels comply with the minimum measures endorsed by the legislature in force.

COMMUNICATION AND DISSEMINATION

The collected data will not be disseminated, sold or exchanged with third-parties without the express consent of the Data Subject, except for any communications to authorised third parties - committed to such confidentiality or appointed as Chief Data Processors under art. 29 of Legislative Decree no. 196/2003 - (e.g. IT support firms) and only where necessary to fulfil the purpose indicated in this Information Notice. Personal data may be communicated to competent authorities as required by the laws in force.

RETENTION TIMES

Personal data is retained for the time required to interact with the Data Subject and exchange information.

RIGHTS OF THE DATA SUBJECT

You are entitled to execute your rights as illustrated in Arts. 7, 8, 9 and 10 of Legislative Decree no. 196 of June 30, 2003 by contacting the Data Processer. In particular, according to art. 7 you are entitled to obtain confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form. The Data Subject has the right to obtain indications on: a) to receive information on the origin of the personal data; b) on the purpose and processing methods; c) on the logic used in the case where the data is processed using electronic equipment; d) on the personal data of the Controller, the persons in charge and the designated representatives pursuant to Art, 5 paragraph 2; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as Designated Representatives for the Country or Persons in Charge of Processing. The Data Subject has the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. The Data Subject is entitled to oppose, totally or partially: a) processing of personal data, for legitimate reasons, despite them being relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

DATA CONTROLLER, CHIEF DATA PROCESSOR AND PRIVACY COMMUNICATIONS

The Data Controller is Roberto Cavalli S.p.A., with registered office in (20122) Milano (MI), in Piazza San Babila no. 3. Pursuant to art. 29 of Legislative Decree 196/2003 the Data Controller has appointed Triboo Digitale S.r.l. with registered office in Viale Sarca, 336 - 20126, Milan (MI) Italy, as the Chief Data Processor in charge of the processing of personal data for purposes related to the managing the sales and transactions on the websites www.robertocavalli.com and www.robertocavalli.it, for instance, the management of product orders, sales and deliveries, returns and warranty management and all other activities related to the sales of products via the Sites, in addition to the activities related to the creation, ordinary and extraordinary management, and maintenance of the Sites themselves. An updated list of the Chief Data Processors, appointed by the Data Controller under art. 29 of Legislative Decree no. 196/2003, is available at the registered office of the latter. For all communication under art. 7 et seq. of Legislative Decree no. 196/2003 as amended, please contact the Data Controller at privacy@robertocavalli.com.

CONFERRAL OF DATA

The conferral of data is optional; however lack of consent to provide the same information will make it impossible for the Data Controller to process the requests submitted.

CONSENT

Pursuant to art. 23 of Legislative Decree no. 196/2003 and the correct processing of the request submitted via the "Contact Us" section of the corporate website, consent to the processing of the above data is necessary as the same are collected outside of any previous contractual agreements

□ On reading the information notice under art. 23 of Legislative Decree no. 196/03, I hereby grant my consent for the data I have conferred to be used to process my request and receive a response from the same Data Controller Roberto Cavalli S.p.A.

INFORMATION NOTICE FOR USER WEBSITE REGISTRATION

Personal Data Protection Code

UNDER ART. 13 of Legislative Decree no. 196 of 30.06.2003

Under the provisions of art. 13 of Legislative Decree no. 196/2003 as amended, the company Roberto Cavalli S.p.A., with registered office in (20122) Milan, in Piazza San Babila no. 3, in its capacity as Data Controller, hereby informs all users requesting registration on the www.robertocavalli.com and www.robertocavalli.it websites, in their capacity as Data Subjects on the scope and purposes of the processing of the collected personal data, the relative communication and dissemination, and the nature of their conferral.

PURPOSE OF THE PROCESSING

1) Registration: the personal data and, more specifically, the data indicated on the registration form (name, surname, email address, telephone number, etc.) related to the Data Subject and provided voluntarily by the same during registration on the Roberto Cavalli S.p.A site, are processed pursuant to the request of the Data Subject to create a personal account and exploit the services provided by the Data Controller via the site and access the online portal. It should be noted that such data may also be used for purposes referred to as “soft spam”.

2) Access to services via the portal: the personal data acquired, including the computer related data (e.g. the IP address), are processed to allow access to the services provided by the Data Controller via the corporate website and reserved to registered users only; i.e. by way of example only, online shopping and payments as illustrated in full in the online platform Terms and Conditions available via the following link.

3) Sending of advertising materials, direct marketing, statistics and market research: when consent is granted, personal data, such as email address and telephone number, are also processed to send information messages and commercial and promotional communications on the activities and services provided by the Data Controller, via automated mechanisms (such as email and text messages) and also traditional methods (such as telephone contact with or without and operator), in full compliance with the principles of fairness and lawfulness and any provisions foreseen by the laws in force.

In any case, processing shall take place in accordance with the principle of fairness and lawfulness and the provisions of the laws in force.

PROCESSING OPERATIONS

The processed personal data is sent to the Data Controller's server or servers managed by third parties (appointed for the purpose as Chief Data Processors under art. 29 of Legislative Decree no. 196/2003 as amended). Personal data is processed using electronic and telematic systems by specifically designated officers and/or chief data processors inside and outside the company. Data is stored in electronic archives whose security levels comply with the minimum measures endorsed by the legislature in force.

In particular, for the purpose of sending advertising materials, direct marketing, statistics and market research, commercial and promotional communications on the activities and services provided by the Data Controller the same shall take place (again according to the provision of art. 130m par. 1 and 2 of Legislative Decree no. 196/2003 as amended) by means of:

- automated contact methods, using automated calling or call communication means without the intervention of an operator, email, facsimile, MMS- or SMS-type messages or other means for the purposes referred to therein;

No Personal data collected will be disseminated, sold, exchanged or communicated to third-parties other than the Data Controller without the express consent of the Data Subject. Dissemination to third-parties, other than the Data Controller, the Chief Data Processors, inside and also outside the corporate structure, and the Designated Officers assigned to the relative processing and appoint under arts. 29 and 30 of Legislative Decree no. 196/2003 as amended, is foreseen, where necessary to fulfil the above illustrated scope and purposes, to: individuals and third-party enterprises providing technical and IT support, marketing companies, who undertake to pursue the illustrated scopes and purposes in a correct and transparent manner. In any case, processing by third-parties shall only take place in accordance with the principle of fairness and lawfulness and the provisions of the laws in force.

RETENTION TIMES

Data shall be retained for the time required to process the purpose of the account created by the Data Subject to access the services provided by the Data Controller via the corporate website. In any case, the data shall be retained until the Data Subject requests the cancellation of the account, or until the same is closed by the Data Controller under the portal terms and conditions.

As regards the processing for purposes related to the sending of commercial and promotional communications on the Data Controller's services and the sending of information messages regarding its business activities, the data will be retained for a maximum of two years from first contact, unless the Data Subject opposes the processing of the same. The Data Subject may oppose the processing independently for one or the other sending methods (traditional or automatic), in particular, for telephone numbers included in phone books, opposition of such processing can be effected by referring to the Public Register of Oppositions, whilst for email addresses, opposition can be effected by cancellation via a specific link. In any case, the cancellation can be requested by email at the following address privacy@robertocavalli.com.

RIGHTS OF THE DATA SUBJECT

The Data Subject is entitled to execute his rights as illustrated in Arts. 7, 8, 9 and 10 of Legislative Decree no. 196/2003 as amended, by contacting the Data Processor. In particular, according to art. 7 you are entitled to obtain confirmation as to whether or not personal data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form. The Data Subject has the right to obtain indications: a) on the origin of the personal data; b) on the purpose and processing methods; c) on the logic used in the case where the data is processed using electronic equipment; d) on the personal data of the Data Controller, the Chief Data Processors and the designated representative pursuant to Art, 5 paragraph 2; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such data in their capacity as designated representatives for the Country, Chief Data Processors or designated officers. The Data Subject has the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. The Data Subject is entitled to oppose, totally or partially: a) processing of personal data, for legitimate reasons, despite them being relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

DATA CONTROLLER, CHIEF DATA PROCESSOR AND PRIVACY COMMUNICATIONS

The Data Controller is Roberto Cavalli S.p.A., with registered office in (20122) Milano (MI), in Piazza San Babila no. 3. Pursuant to art. 29 of Legislative Decree 196/2003 the Data Controller has appointed Triboo Digitale S.r.l. with registered office in Viale Sarca, 336 - 20126, Milan (MI) Italy, as the Chief Data Processor in charge of the processing of personal data for purposes related to the managing the sales and transactions on the website www.robertocavalli.com and www.robertocavalli.it, for instance, the management of product orders, sales and deliveries, returns and warranty management and all other activities related to the sales of products via the Sites, in addition to the activities related to the creation, ordinary and extraordinary management, and maintenance of the Sites themselves. An updated list of the Chief Data Processors, appointed by the Data Controller under art. 29 of Legislative Decree no. 196/2003, is available at the registered office of the latter. For all communication under art. 7 et seq. of Legislative Decree no. 196/2003 as amended, please contact the Data Controller at privacy@robertocavalli.com.

CONFERRAL OF DATA

Conferral of data is optional, but essential, as refusal to such conferral will make it impossible for the Data Controller to create the personal account required to provide the services provided by the latter via the corporate website and reserved to registered users.

As regards the conferral of data for marketing purposes, this is optional and refusal to such conferral will not effect or compromise the main processing operations, although it will be impossible for the Data Processor to perform the ancillary operations.

CONSENT

Under art. 23 and 24 of Legislative Decree no. 196/2003 as amended, the consent to the processing of personal data to create a personal account so as to exploit the services provided by the Data Controller via the corporate website reserved to registered users, is not required as the same is collected to process the obligations arising from the contract that the Data Subject has entered into.

Under art. 23 and 24 of Legislative Decree no. 196/2003 as amended, the consent to the processing of personal data for the sending of commercial and promotional communications on the services provided by the Data Controller and the sending of information messages regarding the activities of the same, is however required. Under the Guidelines regarding promotional and anti-spam activities, the Guarantor for the protection of personal data clearly states that no consent is required for what is referred to as “soft spam”.

Pursuant to the privacy law, Roberto Cavalli S.p.A., with registered office in Milan (20122), Piazza San Babila no. 3, Data Controller for the processing of data collected via this website hereby informs all users that the indicated website uses “third-party” profiling cookies which allow the sending of advertising messages which meet the preferences of the user. For further information, also on technical cookies used on the website, and to deny consent to the setting of individual cookies, please refer to the full cookies information notice
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